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W.S. BADCOCK CORPORATION v. C.I.R.

No. 73-1948.

491 F.2d 1226 (1974)

W. S. BADCOCK CORPORATION, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

March 29, 1974.

Attorney(s) appearing for the Case

Sherwin P. Simmons, Harold W. Mullis, Jr., Tampa, Fla., for petitioner-appellant.

Scott P. Crampton, Asst. Atty. Gen., Tax Div., U.S. Dept. of Justice, Ernest J. Brown, Acting Chief, Appellate Sec., Tax Div., Lee H. Henkel, Jr., Chief Counsel, I. R. S., Lawrence B. Gibbs, Acting Chief, Chris J. Ray, Atty., Richard W. Perkins, Murray S. Horwitz, Elmer J. Kelsey, Attys., Tax Div., Dept. of Justice, Washington, D.C., for respondent-appellee.

Before WISDOM, AINSWORTH and GEE, Circuit Judges:

GEE, Circuit Judge:

Taxpayer appeals from a judgment of the United States Tax Court which found deficiencies in its income tax. W. S. Badcock Corp., 59 T.C. 272 (1972). Involved are returns for its tax years ending in 19641 and 1966-68, aggregate additional taxes exceeding seven hundred thousand dollars, and something of a threat to accrual basis tax reporting. Since the facts of the case are painstakingly...

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